Evaluating the Subject-to-Tax Rule in Nigeria: Implications, Challenges, and Strategic Considerations Amid Global Tax Reforms

Abstract

The OECD’s two-pillar solution addresses the tax challenges of digitalization, with the Subject to Tax Rule (STTR) and GloBE Rules ensuring minimum taxation. This article explores the application of the STTR in Nigeria, assessing its potential for generating revenue while considering the high costs of implementation and the country’s strategic alternatives.